G.R. No. 200265 ; December 2, 2013
LAURA E. PARAGUYA, Petitioner, vs. SPOUSES ALMA ESCUREL-CRUCILLO and EMETRIO CRUCILLO, and the REGISTER OF DEEDS OF SORSOGON, Respondents.

FACTS

Petitioner Laura Paraguya filed a complaint for annulment of Original Certificate of Title (OCT) No. P-17729, alleging that respondent Alma Escurel-Crucillo obtained the title over the subject properties through fraud and deceit. Paraguya claimed to be the lawful heir of their common ancestor, Ildefonso Estabillo, and asserted that Escurel was merely an administrator. The properties were originally owned by Estabillo. Escurel had acquired title via a free patent application, supported by an affidavit of adjudication and an affidavit from her brother, Adonis Escurel.
The Regional Trial Court (RTC) ruled in favor of Paraguya, ordering the cancellation of OCT No. P-17729. The RTC found fraud due to a discrepancy in the land area stated in Adonis’s affidavit (8,392 sq. m.) and the area in the title (30,862 sq. m.), and deemed Escurel’s affidavit of adjudication self-serving. The Court of Appeals (CA) reversed the RTC, dismissing Paraguya’s complaint. The CA held the title had become indefeasible and that Paraguya failed to establish a real-party interest.

ISSUE

Whether the Court of Appeals correctly dismissed Paraguya’s complaint for annulment of title.

RULING

The Supreme Court denied the petition and affirmed the CA. The ruling is anchored on two primary legal principles. First, under Section 32 of Presidential Decree No. 1529 (Property Registration Decree), a decree of registration and the Torrens title issued upon it become incontrovertible one year after its entry. OCT No. P-17729 was issued on August 24, 1979. Paraguya’s action, filed only in December 1990, was filed over a decade beyond the one-year statutory period. Consequently, the title was no longer subject to challenge on grounds of fraud.
Second, the Court upheld the CA’s finding that Paraguya failed to prove her ownership claim to constitute a real-party interest. The titulo posesorio (a Spanish title of possession) she presented as evidence was inadmissible for proving ownership. Pursuant to Presidential Decree No. 892, which took effect in 1976, Spanish titles could no longer be used as evidence of land ownership in registration proceedings under the Torrens system. Since Paraguya only presented this document during trial in the 1990s, it was correctly accorded no evidentiary value. Thus, lacking both a timely action and sufficient proof of ownership, her complaint was properly dismissed.